Dalenko v. Collier

The trial court did not err in entering judgment out of session when plaintiff failed to timely object to such entry. The trial court did not err in imposing Rule 11 sanctions because a certification by an attorney required by a prior “gatekeeper order” does not insulate plaintiff from Rule 11 sanctions. Plaintiffs action was barred by collateral estoppel and by judicial immunity. The trial court did not err when it imposed Rule 11 sanctions on plaintiff without submitting this issue to a jury. The trial court did not err in deciding to award attorney’s fees as a sanction under Rule 11 of the…